Privacy Policy for Flare by Flatlogic EU, UAB

Effective Date: 23/04/2024

1. Introduction

Welcome to Flare by Flatlogic EU, UAB ("Flare", "we", "us", "our"). Flare is an innovative tool designed to interact with your Gmail account to manage unread emails by classifying and automatically responding to them based on your predefined instructions. This privacy policy outlines how we handle your personal information related to your use of Flare and aims to help you understand our data practices. We are committed to protecting your privacy and ensuring that your personal data is handled responsibly and in compliance with applicable laws.

By using Flare, you trust us with your information, and we are committed to maintaining that trust. This policy explains what information we collect, how we use it, and your rights regarding your data.

2. Information We Collect

2.1 Email Information

  • Access and Read:Flare accesses the unread emails in your Gmail account to classify them. The tool reads the content of these emails strictly for classification and to formulate appropriate responses.
  • No Storage: We do not store the content of your emails on our servers longer than necessary to provide the response functionality. Emails are processed and then removed in accordance with our data retention policies.

2.2 Personal Information

  • During Registration: When you create an account for Flare, you provide us with personal information that includes your name, email address, and contact details. This information is essential for setting up your account and verifying your identity.
  • User Support: If you contact our support team for assistance, we may collect additional information to help resolve your query.

2.3 Automated Information Collected by Our Servers

  • Usage Data: Information on how you use Flare, including the frequency and scope of your interactions with the service.
  • Technical Data: This includes your IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, and other technology on the devices you use to access Flare.
  • Analytics: We collect data necessary for us to monitor our performance, improve our service, and enhance user experience.

3. How We Use Your Information

3.1 To Provide and Maintain Our Service

  • Service Operation: Using your information to operate, maintain, and provide to you the features and functionality of Flare.
  • Account Management: Managing your account preferences, facilitating account creation and logon processes.

3.2 To Communicate with You

  • Service Communications: Sending you technical notices, updates, security alerts, support, and administrative messages.
  • User Feedback: Asking for your feedback or to participate in surveys to help us improve our services.

3.3 To Improve and Personalize the User Experience

  • Enhancements: Analyzing usage patterns to improve the interface and functionalities of Flare.
  • Customization: Tailoring the user experience by utilizing preferences and settings to make Flare more user-friendly.

3.4 Legal and Compliance Obligations

  • Compliance: Ensuring compliance with applicable laws and regulations.
  • Security: Implementing measures to enhance the security and integrity of our service.

4. Sharing Your Information

4.1 General Principles for Sharing Your Information

  • Confidentiality Commitment: We do not sell, rent, lease, or give away your information to third parties for their marketing purposes without your explicit consent. Any data shared is done in accordance with this privacy policy and with the strictest security measures in place.

4.2 Specific Scenarios Where Your Information May Be Shared

  • Service Providers: We engage various third-party service providers who perform functions on our behalf including hosting, email communication, analytics, and customer support services. These service providers are bound by contractual obligations to ensure the confidentiality of your data and to use it only for the purposes for which we disclose it to them.
  • Compliance with Laws: We may disclose your information where required by law, subpoena, or other legal processes, or if we believe that such action is necessary to:
    • Comply with the law and the reasonable requests of law enforcement.
    • Enforce our legal agreements and policies.
    • Protect the security or integrity of our Service.
    • Exercise or protect the rights, property, or personal safety of Flatlogic, our users, or others.

4.3 Transfers of Business

  • Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company, your information may be among the assets transferred. You will be notified via email and/or a prominent notice on our Service of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

5. Data Security

5.1 Our Commitment to Security

  • Security Measures: We have implemented appropriate technical and organizational security measures designed to protect your personal information from accidental loss, unauthorized access, use, alteration, or disclosure. These include using encryption, firewalls, secure software development standards, and access control measures.
  • Data Encryption: All sensitive and private data exchanged between your device and our servers is transmitted over SSL technology ensuring its security.

5.2 Data Breach Procedures

  • Rapid Response: In the event of a data breach, we have implemented robust procedures to act quickly to secure affected systems, determine the nature and scope of the breach, and to notify all affected individuals and regulatory authorities, where applicable, within 72 hours of discovering the breach.
  • Continuous Improvement: We continuously refine our security practices and upgrade our security measures in response to new threats and the latest developments in the field.

5.3 User Responsibility

  • Secure Account Management: We encourage you to use strong passwords and to be responsible for keeping your login and account information private.

6. Google User Data and API Integration

6.1 Handling Google User Data

  • Access and Use: Flare accesses only unread emails in your Gmail account to perform classification and automated responses, strictly according to the permissions granted by you during the OAuth consent process.
  • Data Storage and Sharing: No Google user data is stored beyond what is necessary to fulfill the functions you have authorized. We do not share this data with any third parties except as needed for the operation of Flare and as described in Section 4.

6.2 In-Product Privacy Notifications

  • Detailed notifications within the Flare interface inform you about the use of your Google user data. These are designed to be prominent and easily accessible to ensure you are always informed about how your data is being used.

6.3 Updates and Consistency

  • We regularly update our privacy policy to reflect any changes in our practices or the legal landscape. This policy is consistently linked across our homepage, product interfaces, and OAuth consent screens.

6.4 Restrictions on Use of Google Workspace APIs

  • Google Workspace APIs are not used to develop, improve, or train generalized AI and/or ML models.

7. Your Rights

7.1 Access and Control of Your Information

  • Access and Updates: You have the right to request access to the personal information we hold about you and to ask for your information to be corrected, updated, or erased. You can typically manage your account settings directly or contact our support team for assistance.
  • Data Portability: You have the right to receive a copy of the data we have on you in a structured, machine-readable format where technically feasible.

7.2 Consent and Withdrawal

  • Consent Management: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
  • Opt-out Preferences: You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Service may become inaccessible or not function properly.

7.3 Complaints

  • Regulatory Complaints: If you believe that we have not adhered to this policy or if you have any other complaints regarding our privacy practices, you have the right to lodge a complaint with a supervisory authority.

8. International Data Transfers

8.1 Transfer Mechanisms

  • Global Operations: Given our global operations, we may transfer and access your personal information from around the world, including the United States and other jurisdictions. We comply with applicable legal requirements providing adequate protection for the transfer of personal information to and from countries outside of the European Economic Area (EEA).
  • Safeguards: We use approved contract clauses, rely on the European Commission’s adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to other jurisdictions.

9. Children's Privacy

9.1 Protecting Children's Privacy

  • Age Limitations: Flare is not directed to individuals under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information from our servers immediately.
  • Parental Consent: If parental consent is required under the laws of your jurisdiction, we will take all necessary steps to comply, including verifying the consent given by the parent or guardian of the child involved before any personal data is used or processed.

10. Updates to This Policy

10.1 Revisions and Modifications

  • Changes to the Policy: We may update this privacy policy from time to time in response to changing legal, technical, or business developments. When we update our privacy policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.
  • Notification: You can see when this Privacy Policy was last updated by checking the “effective date” displayed at the top of this Privacy Policy. We will notify you of any changes through the usual channels of communication, such as by posting a prominent notice on our website or by directly sending you a notification.

11. Contact Us

11.1 How to Reach Us

  • Feedback and Questions: If you have any questions, feedback, or concerns about our use of your personal information, please contact our privacy team by email at [email protected].
  • Office Address: Flatlogic EU, UAB, Kareivių g. 7, LT-09108 Vilnius